USE OF MODERN TECHNOLOGY TO IDENTIFY SUSPICIOUS/SUBJECT TO MANDATORY CONTROL TRANSACTIONS X-COMPLIANCE project

RELEVANCE OF THE PROPOSED SOLUTION WHY? The law requires credit institutions to identify certain types of transactions and exercise internal controls in respect of them. WHY IS IT IMPRORTANT? Designated officials are personally responsible for reliable identification of transactions and their timely reporting. As part of its supervisory regime, the regulator is particularly responsible for ensuring the full extent and timeliness of the identification of the relevant transactions. Failure to identify or late identification of transactions, as well as failure to report or incomplete/inaccurate/late reporting of such transactions, is punishable by law (up to the revocation of the license). The deadlines for the identification and analysis of transactions established by law are extremely tight. TYPES OF TRANSACTIONS REQURING IDENTIFICATION AND SUBSEQUENT ANALYSIS SUBJECT TO MANDATORY CONTROL SUSPICIOUS .

IDENTIFICATION OF MATCHES PRODUCT DESCRIPTION ANALYSIS of transaction details for possible criteria match IDENTIFICATION OF MATCHES of transaction details with the criteria → transaction flagging ISSUANCE OF AN ALERT which includes: 1) flagged transaction details; 2) specifying the criterion that resulted in the flagging of the transaction ANALYSIS OF TRANSACTION DETAILS/CUSTOMER SPECIFICS for final decision on possible action (report to Rosfinmonitoring, request for additional info, etc.) The solution is a customizable automatic filter designed to identify certain types of customer transactions performed by a credit institution for their subsequent analysis and decision on the expediency of: its reporting to the designated authority; and implementation against the customer of the measures provided by law. When the details of a transaction match certain/user-customizable criteria for suspicious transactions or transactions subject to mandatory control, the system flags such transaction.

THE PROPOSED SOLUTION ENABLES USERS to identify transactions meeting applicable requirements; to use automation to mitigate the risk of a human error during the identification of a certain type of transactions; to leverage the system's intellectual functions to mitigate the risk of "bypassing" the requirements; to compare the customer profile with the nature of transactions specific to the account used, and thereby implement a risk-based approach recommended by the Bank of Russia, which allows financial institutions to make informed decisions regarding the customer; to mitigate the risks associated with the use and support of primitive internal (IT) solutions; to update the system as necessary through the use of technical support; to isolate the system from the existing sanctions regime and eliminate the risks posed by it.

WHY INTERFAX? For more than 25 years, the Interfax Group has been developing information products designed to help companies make important business decisions, including in the area of ​​risk management. Interfax cooperates with Rosfinmonitoring on AML/CFT matters within the framework of an information sharing agreement and a working group (http://www.fedsfm.ru/activity/cooperation). The X-Compliance service developed by the Interfax Group is recommended by the regulator (the Bank of Russia) as a source of information legally available to businesses. The use of the proposed solution in conjunction with the X-Compliance service enables users to not only: 1) identify the criteria affecting the customer risk profile in accordance with the Bank of Russia requirements and the company's internal regulations; And 2) automatically assess the level of risk posed by the customer based on the nature of its activities and unique features, while taking into account the whole set of factors influencing the customer risk profile; but also 3) match the customer profile against the nature of transactions specific to the account used, and thereby implement a risk-based approach recommended by the Bank of Russia, which allows financial institutions to make informed decisions regarding the customer.

OUR AREA OF EXPERTISE - development and maintenance of a service for the identification, assessment and effective management of compliance risks. Combating corruption Use of data on income and property of Russian public servants to verify the source of the PEP's funds. Identification of potential conflicts of interest related to the counterpart's PEP status Assessment of the corruption risk associated with the establishment of a relationship with a counterparty that includes a PEP/PEP's associate Corruption risk management in accordance with the FATF Recommendations in cooperation with domestic PEPs. Insider information Matching the details of a legal entity against the register of legal entities known for their use of insider information and market manipulation. FATCA/CRS TIN verification. AML/CFT Identification of PEPs and their close associates Identification of the customer ownership structure and its beneficial owner Assessment of the level of the customer risk and possible fine-tuning of the risk index in accordance with the user's requirements. Recording of the identification data in the file compiled in accordance with legislative requirements Automatic verification of customers of interest to the company with subsequent recording of the verification parameters and findings. Sanctions Identification of the sanctions risk associated with: non-compliance with the sanctions regime; making a payment featuring a sanctions-sensitive element; possible negative consequences for a business in case of untimely updating of the sanctions lists; enforcement of the "Rule 50%" against the company; potential loss of business reputation both domestically and internationally.

SOURCES OF DATA USED IN ENTITY ANALYSIS DATA SOURCES FOR ANALYSIS Payment discipline indices (Paydex) Court rulings and enforcement proceedings, lawsuits Company personnel data Tender information, advisory systems, specific indicators Real estate data Online data News and social media Credit history Intellectual property Transactions and data generated by mobile credit readers Darknet Traditional online financial ratios Tax burden and productivity analysis

TECHNICHAL SPECIFICATIONS TECHNOLOGICAL PROCESSES: large volumes of data for analysis; real time; reinforcement learning; deep machine learning; artificial intelligence; flexibility; cybersecurity. BUSINESS ANALYSIS TOOLS: recognition; forecasting; creative processes; decision making.

RUSSIAN COMPANIES: RISK LEVELS (Q4) (Q2) (Q1) (Q2) (Q3) Low risk Medium risk High risk (fiscal) High risk (non-fiscal)

Any questions? Just ask. tel./fax: +7(495) 357-88-08 E-mail: xco-help@interfax.ru